RCM Pulse Weekly

Regulatory: Medicare Advantage Open Enrollment Live October 15 — 34M Members Projected; Average Premium $12/mo; PFS Final Rule Expected ~4 Weeks Out • Prior Authorization: UHC Removes PA for 5 Additional Cardiology Procedures (Week 3 of Rollout); Cigna Launches EviCore Strategic Review; CMS-0057-F FHIR APIs Due January 1, 2027 (77 Days) • AI & Automation: AKASA Autonomous Inpatient Coding Spans Full CDI Workflow; Waystar AltitudeAI Processes 2B+ Daily Eligibility Checks; Suki Raises $90M Series E • Coding: CPT 2027 Official Release — 299 New Codes, Maternity Bundle Deleted, 10 AI-Adjacent Codes, ABA Expands 10→14 Codes • Revenue Velocity: MGMA 2026 — Median Days in A/R 38.2; Top-Quartile Clean Claims Rate 97.2%; Net Collection Rate ≥97.0% Target • Technology: Confido Health $12.5M Series A; Sunbound $24M + Richter Acquisition; KPMG Reports 79% Healthcare IT M&A Decline • Compliance: FTC Warning Letters to 24 Healthcare Companies — “Floor Not Safe Harbor” on Price Transparency; 3 Simultaneous Deadlines Active • Independent Practice Watch: 84% Higher Administrative Costs vs. Health Systems; 48% Report Rising Denials; “Where You Should Be” Benchmark Across 6 KPI Dimensions • Specialty: Primary Care, Cardiology, Orthopedics, Oncology, ABA, Radiology, Neurology

Regulatory: CMS Issues CMS-9882-F Transparency in Coverage Final Rule October 5 — Machine-Readable Files for All In-Network Rates and Out-of-Network Allowed Amounts, Price Comparison Tool Requirement, Compliance Enforcement Beginning December 5 • Prior Authorization: AMA Survey Shows 88% of Physicians Reporting Delays in Care From Prior Auth, 40% of Appeals Taking More Than 2 Weeks; Open Enrollment Opens October 15 With 7 Days to Prepare • AI & Automation: HFMA AI Governance Framework Released October 6 — Six-Domain Model Covering Transparency, Accountability, Fairness, Safety, Privacy, Reliability; 67% of Health Systems Planning AI Pilots in Next 12 Months • Coding: Week Two of FY 2027 ICD-10-CM Remit Audit — K57.30 vs. K57.20 Diverticulosis Splits, Z68 Body Mass Index Updates; Practices Reporting Up to 12% Claim Adjustment Rates on New Codes • Revenue Velocity: HFMA 2026 Revenue Cycle Benchmark Report — Median Days in A/R at 41.2 Down From 43.8; Clean Claims Rate 95.3%; Net Collection Rate 97.6% • Technology: Waystar Acquires Iodine Software for $1.25B — KLAS Research Assigns “A” Grade; Combined Platform Covers Autonomous Coding Plus Denial Prevention • Compliance: CMS HETTS EDI Testing Phase Ends December 1 — All Providers Must Migrate to HIPAA Transaction Standards; 277CA, 835, 837 Compliance Required • Independent Practice Watch: Veradigm 2026 Independent Practice Survey — 94% Approached About Acquisition or Partnership; 78% Report Declining Reimbursement for Same Services • Specialty: Primary Care, Cardiology, Orthopedics, Oncology, Radiology, Neurology, Mental Health and Gastroenterology

Regulatory: CMS Finalizes GLOBE September 30 — a Mandatory Five-Year Part B Drug Model Benchmarked to 19 Countries, Starting January 1 in Areas Holding 25% of Original Medicare, With Savings Cut From $2.3B to $80M a Year — Plus a Proposed 1.68% Conversion-Factor Cut • Prior Authorization: 2027 MA Landscape Shows Centene Exiting 344 Counties, 33 Health Systems Leaving MA Contracts, and Only 7% of Practices Reporting Faster Prior Auth • AI & Automation: Payers Shift From Denials to Clawbacks While 34% of Medical Groups Build Their Own AI Tools • Coding: Week One of FY 2027 ICD-10-CM and NCCI v32.3, Medicare’s Duplicate Lab and Modifier 91 Reminder, 91 Days to CPT 2027 • Revenue Velocity: Kodiak Finds Initial Denials Down to 10.63% but Clawbacks Up to 1.57% and 60-Day Cash Down • Technology: H1’s $77.6M CMS National Provider Directory Contract and MA Directories on Plan Finder • Compliance: IDR Analysis Finds Insurers Lost ~25% of Line Items by Default as the IDR Gateway Opens • Independent Practice Watch: 97% of MGMA Attendees Report Higher Operating Costs • Specialty: Primary Care, Cardiology, Orthopedics, Oncology, Rheumatology, Ophthalmology, Radiology, Mental Health, GI and Pathology

Regulatory: CMS Posts Preliminary CY 2027 CLFS Rates September 21 — 1,171 of 1,528 Codes Below 2026 Medicare, ~16% Lower on Average, 775 Tests at the Full 15% Cap, Molecular Pathology −22% and Genomic Sequencing −23% Uncapped, Comments Due Around October 21 — and a Continuing Resolution Through December 11 Means No October 1 Claims Hold • Prior Authorization: Aetna Bundles Chemotherapy, Immunotherapy, Radiation and MRI/CT Into One Oncology Authorization, Cigna’s R49 Policy Keeps Downcoding 99214/99215 as AAO-HNS Files Opposition, and Humana’s 600,000-Member MA Exit Notices Are Dated October 2 • AI & Automation: Oracle Health Announces Five Upstream AI Revenue Cycle Capabilities September 23, While Black Book Finds Only 19% of Practice AI Users Report Meaningful Net Work Reduction and Ambient Scribes Drive Payer Downcoding • Coding: Six Days to ICD-10-CM, ICD-10-PCS, the October HCPCS Quarterly and NCCI Q4 Edits — a Three-Day Readiness Test • Revenue Velocity: HCA Says Patients Owe More and Pay Less as Members Slide From Silver to Bronze, 32% of Groups See Rising No-Shows • Technology: Black Book’s 2027 Vendor Rankings, 70% Planning RCM Automation Spend, 85% Demanding Measurable First-Year Results, and R1–Humata Closing at Quarter End • Compliance: OIG Finds $177.8M in Unsupported Humana and UnitedHealthcare MA Diagnoses Including Stroke, Heart Attack, Embolism and Sepsis • Independent Practice Watch: 94% Say Costs Outrun Reimbursement, 72% Can’t Retain RCM Staff, and Only 1% of Physician Office Labs Reported Lab Rate Data • Specialty: Primary Care, Cardiology, Orthopedics, Oncology, Radiology, Pathology, GI, Neurology, Mental Health and ENT

Regulatory: The CMS-1848-P Comment Window Closed September 14 and the Planning Window Opened — 105 Days to a Proposed 100%/50% Payment Split That Pays the Most Expensive Same-Day Service in Full and Halves Everything Else Billed With Modifier 25 Alongside a 0-, 10- or 90-Day Global Procedure, Conversion Factors of $33.17 and $32.84, Skin Substitutes Moving From a Single $127.28 Per-Square-Centimeter Incident-To Rate to Three Flat FDA-Classification Tiers, and G2211 Converting From a Standalone HCPCS Code Into a Modifier Paying 16% of the Base E/M or 32% Inside a Qualifying ACO • Prior Authorization: UnitedHealthcare Eliminates Roughly 1,700 CPT Codes — About 30% of Its Entire Book — Across Commercial, Medicare Advantage, Community Plan, Individual Exchange and Oxford Plans on October 1, Covering Lesion Excisions, Fracture Care, Joint Injections, Arthroscopies, Colonoscopies, Endoscopies, Biopsies, Hernia Repairs, Genetic and Lab Testing, Chiropractic, Therapy, Home Health and DME — While Cigna Targets 70% Standardization by Year End, the Industry Pledge Framework and Four CMS-0057-F FHIR APIs Both Land January 1, and WISeR Survives a 46–50 Senate Vote to Run Through 2031 Across Six States • AI & Automation: CPT 2027 Adds 10 AI Codes for a Total of 43 and Refreshes Appendix S to Sharpen Assistive From Augmentative, Against 59% of Organizations With No AI Anywhere in the Revenue Cycle and Only 2% Fully Integrated — Plus Ambient Documentation at 29% of Physicians and 62.6% of Epic Hospitals, UF Health Deploying R1’s Phare OS September 9, and Gartner Forecasting 40% of Agentic Projects Cancelled by End of 2027 • Coding: Thirteen Days to FY 2027 ICD-10-CM — 190 New Billable Codes Inside 238 Total Entries, 21 Outright Deletions and 30 Codes No Longer Reportable, With I42.0 Demoted to a Non-Billable Header and Z68.1 Replaced by Z68.18 and Z68.19 — and 105 Days to CPT 2027’s 453 Editorial Changes: 299 New, 74 Revised, 80 Deleted, Including the Replacement of the Global Maternity Bundle • Revenue Velocity: Electronic Prior Auth Adoption at 40% but Only 35% True X12 278, $11.7 Billion in Medical Savings Still Unclaimed, A/R Days Up 2.4 at the Median on Medicare Advantage Backlogs, 41% of Providers Above a 10% Denial Rate, and Pre-Service Collections Rising From 16% to 21% • Technology: Waystar Tops the KLAS 2026 RCM Suites Report on Deep-Adopter Satisfaction, a $189.28B Market Heading to $505.8B by 2035, Outsourcing From $61.7B to $126.5B by 2032 With 70% of Systems Planning to Expand • Compliance: Price Transparency Enforcement Passes Its Sixth Month and Four FHIR APIs Come Due in 105 Days — a Payer Mandate With a Provider Dependency • Independent Practice Watch: 89% Say Staying Independent Got Harder, 88% Among Practices of Five or Fewer, Medicare Payment Up 10% Against 63% Cost Growth Since 2001 and Down 33% Inflation-Adjusted • Specialty: Dermatology and Otolaryngology at −9%, Orthopedics −7% With Hand Surgery −5%, Hem/Onc −1.5%, Cardiology ~+1%, Interventional Radiology +3%, GI Carrying the 2.5% Efficiency Adjustment, Neurology at an 18% Denial Rate — and the Compounding Risk That the Deepest-Cut Specialties Also Carry the Heaviest Modifier 25 Exposure

Regulatory: CMS-1848-P Closes Monday, September 14 — Conversion Factors of $33.17 for Qualifying APM Participants and $32.84 for Everyone Else (−1.19% / −1.68%) With a +0.53% Work RVU Budget-Neutrality Adjustment, the Phase-Out of Practice-Expense-Per-Hour Data Anchored to 2007 or Earlier, an Adjusted Indirect PE Allocation for SNF Visits, and an RFI Asking Whether the Facility Versus Non-Facility Differential Is Still Appropriate — Plus Remote Therapy Monitoring Restricted to Established Patients, a Separately Reportable Initiating Visit and Employed Clinical Staff Rather Than Contractors, New Shared Medical Appointment Coding, Two New Clinical-Staff Advance Care Planning HCPCS Codes, and the Telehealth Retroactivity Refund CMS Asked Practices to Work After the 43-Day Shutdown • Prior Authorization: Texas HB 3812 Took Effect September 1 and Now Evaluates Gold-Carding Eligibility Against a Full Year of Requests Instead of Six Months, Joining Louisiana, Michigan, Vermont and West Virginia — While CMMI Pilots the Same Concept Inside WISeR Across New Jersey, Ohio, Oklahoma, Texas, Arizona and Washington at 72-Hour and 48-Hour Decision Clocks, PA Denials Run 31% Higher Year Over Year, 29 Health Systems Exit Medicare Advantage Over Denials and Slow Payment, and Four FHIR APIs Come Due in 112 Days • AI & Automation: Maverick Medical AI Ships a Clinical-to-Revenue Foundation Model September 8, Xsolis Makes a GenAI Peer-to-Peer Clinical Synopsis Generally Available Against 89% User Reliance for Denial Prevention, and Abridge Wires NEJM and JAMA Into Ambient Documentation — While Innovaccer Finds 63% Running AI in at Least One Workflow, Only 8% at Enterprise Scale and 62% Naming Fragmented Data, Not Trust, as the Barrier • Coding: Twenty Days to FY 2027 ICD-10-CM (190 New, 30 Deleted, 4 Revised) and 112 Days to the Larger Event — CPT 2027 Deletes the Bundled Global Maternity Codes for Four-Phase Reporting, Retires 92507, and Adds 58 Category III Codes Including 1072T–1078T, 1054T, 1056T and 1069T–1071T — Plus an EviCore EGD Guideline Update Landing September 16 • Revenue Velocity: The 2025 CAQH Index Records $258 Billion Avoided and a 17% Rise in Cost Avoidance With $21 Billion Still Manual, a 24-Minute $14 Eligibility Call, a $10.97 Manual Prior Authorization Against $5.79 Electronic, and Cleveland Clinic Turning a 15% Denial Rate Into Under 2% Net Controllable Loss at a 92% Overturn • Technology: A $40.58B RCM Software Market Heading to $57.35B by 2030, Billing Outsourcing From $14.90B to $44.30B by 2033, 97% of Organizations Already Outsourcing Something Against 63% Reporting Staffing Gaps and 22% Annual Billing Turnover • Compliance: Price Transparency Enforcement Six Months Live With CMS Running an RFI on Free-Text Fields and Consumer-Display Comparability, and the CMS-0057-F API Deadline That Belongs to Your Payer but Depends on Your EHR • Independent Practice Watch: 84% of Groups Spending More Than Last Year, 80% Saying Medicare Pays Below Cost, and Operating Cost Per FTE Physician Up 63% Since 2013 Against a 1.7% Conversion Factor • Specialty: Radiation Oncology Watching Roughly Half Its High-Complexity Claims Get Flagged or Downgraded Under the New 77402/77407/77412 Tiers, Orthopedics Carrying a −7% Proposed Impact Plus the ASM Low Back Pain Arm, Cardiology 112 Days From Mandatory Two-Sided Risk, Radiology Absorbing Aetna’s 15% Dose-Compliance Reduction, GI Facing a New EGD Criteria Set, SLP Losing 92507, and OB Repricing Every Global Contract

Regulatory: The OPPS/ASC Comment Window Closed August 31 While the CY 2027 PFS (CMS-1848-P) Runs Ten More Days to September 14 — Conversion Factors of $33.1693 / $32.8409 (−1.19% / −1.68%), the 2.5% WFTC Cliff on December 31, a 100%/50% Modifier 25 Stacking Cut With CMS Asking Whether 25% Is More Accurate, G2211 Converting to a 16% Modifier (32% in MSSP and LEAD), the 2007-Era PE/Hour Phase-Out and a New PE Stabilizer, RTM Restricted to Established Patients and Employed Staff — and the Ambulatory Specialty Model Going Live January 1 as Mandatory Two-Sided Risk Across 235 CBSAs at ±9% With No Opt-Out and No Hardship Exemption • Payer Relations: The September 1 Wave Across Six Payers — UnitedHealthcare Caps Allergen Testing at 20 Per Year, B12 Quarterly and Hepatic Fibrosis Semi-Annually While Ending Reimbursement for In Vitro Chemosensitivity Assays; Aetna Docks Radiology 15% on Modifier CT Without “Smart Dose” Compliance; BCBS Michigan Starts a Two-Phase Incident-To Unwind Ending at 80% of the Professional Fee March 1, 2027; BCBS Texas Updates 24 Lab Policies; BCBS North Carolina Restructures Multiple and Bilateral Surgery — Plus the CMS-0057-F HPMS Attestation Passing September 1 and 119 Days to Four FHIR APIs • AI & Automation: Autonomous Coding Takes 44.8% of a $3.86B AI-Coding Market Heading to $10.84B by 2034, With 98.5% E/M and 95.5% ICD Accuracy, 85% Direct-to-Bill and R1 Reporting 97% in Production — and Why 379 New Codes Make October 1 a Model-Retraining Event, Not a Coder-Education One; Prior Auth Automation Clearing 68% of Orders in One Hour at a Sub-1% Auth Denial Rate • Coding: 379 New Codes in a Single Day — ICD-10-CM (190 New, 30 Deleted, 4 Revised, 33 Clinical Topics, With 33 Codes in Category O31.4 Alone), ICD-10-PCS (101 New, 38 Deleted, 50 in New Technology, 79,256 Total), and the HCPCS Level II Update Posted August 18 (88 New Codes, A2046, A4228 at ~$124.54, A6614 at ~$167.99, Plus 19 Home Health Consolidated Billing Additions) — With CPT 2027 Publishing This Month • Revenue Velocity: Expenses Per Physician Up 26.5% Against 9.1% Revenue Growth, 40% of Practices Carrying 3+ Administrative FTEs Per Physician, Automation Named the Top 2026 Cost-Cutting Move at 36%, and A/R Day Targets by Practice Size • Technology: The Agentic Buy-Side Crowds In — Candid Health’s $120M Series D, Raintree Acquiring Spike Technologies, Experity Buying an 86%-Denial-Reduction Platform, Adonis at $40M, and Becker’s Health IT + RCM Ten Days Out • Compliance: September Is the Last Outreach Month Before Medicaid Community Engagement Starts January 1 in 43 States and DC at 80 Hours a Month With a 30-Day Cure Window — Plus Price Transparency Attestation and 10 CMPs in 2025 • Independent Practice Watch: Three Administrative FTEs Per Physician, 95% Reporting Rising Regulatory Burden, Private Equity Behind More Than 90% of Practice Transactions, and 47% of Physicians Now Consolidated With Health Systems • Specialty: Radiology −15% Without Dose Compliance, Cardiology and Low Back Pain Drafted Into Mandatory Risk, Orthopedics −7% With 14–22% Denials, Oncology at −1.5% Against a 340B Repricing, GI Gaining Category I ESD Codes, Behavioral Health at 20–30% Denials With Telehealth Secured Through 2027, and OB Facing Two Code Changes Ninety Days Apart

CY 2027 OPPS/ASC Proposed Rule (CMS-1850-P) Closes August 31: 637 Procedures Off the Inpatient-Only List With 801 More in CY 2028, 618 Surgical Procedures Added to the ASC Covered Procedures List, 340B Drugs Repriced From ASP+6% to ASP−33.4% for a $4.55B Medicare Drug Payment Reduction and $1.15B in Beneficiary Savings, Non-Drug OPPS Rates +8.44% for Budget Neutrality, the 340B Remedy Offset From 0.5% to 3.0%, a +2.4% OPPS and ASC Update, and Site-Neutral Payment Extended to Imaging — With the CY 2027 PFS Still Open Until September 14 • Prior Auth One Year Into the Pledge: 11% of Prior Authorizations Eliminated, 6.5 Million Fewer Requests, 15% Cut in Medicare Advantage, UHC Gold Card at −30% Volume — and 126 Days to the January 1, 2027 Provider Access and Prior Authorization FHIR API Deadline Under CMS-0057-F • The Payer Phone Call Gets Automated: EHVA.ai and CareFactor Target 80% Voice-AI Call Resolution, Cigna Expands AI Care Management to 20% More Customers, and CAQH Finds 50%+ of Health Plans Using Administrative AI Against Just 25% of Providers • Coding Double Header on October 1 (33 Days): FY 2027 ICD-10-CM With 85 Injury, 56 Obstetric and 33 Musculoskeletal Additions, Plus 58 New Category III CPT Codes (0894T–0896T, 1054T–1111T) — and AMA Moves Category III to April, July and October Releases • Revenue Velocity: Denial Management Consumes 50–75 Hours a Week, 41% of Providers Above a 10% Denial Rate, 68% Say Clean Claims Are Harder, 50% Blame Missing or Inaccurate Data, Only 14% Use AI Against Denials — While Automated Eligibility Runs Under $1 vs. $3–$5 Manual • Technology: EnableComp Acquires Helix Advisory August 17 to Close the Zero-Balance Gap, a $30M Cross-Border RCM Facility Closes August 24, and Billing Outsourcing Heads From $7.24B to $21.41B by 2035 • Compliance: Price Transparency Attestation Enforcement Five Months Live While CMS Runs an RFI to Rewrite It, Plus WISeR’s First Eight Months Across Six States and Four MAC Jurisdictions • Independent Practice Watch: Physician Practice Chapter 11 Filings on Pace for 14 vs. 6 in 2025, ~30% of All Healthcare Filings, the $10–50M Liability Tier Up 57% — Yet 69% Still Confident They Stay Independent • Specialty: Orthopedics −7%, Cardiology ~+1%, Radiology +2–3%, Oncology Absorbing the 340B Repricing, Neurology ~0%, Behavioral Health Finishing a Four-Year RVU Transition, GI Gaining From the IPO Phase-Out

CY 2027 Physician Fee Schedule: Proposed 50% Payment Cut on Modifier 25 E/M Visits, 2.5% Efficiency Adjustment, Conversion Factors of $33.17 / $32.84, IPCI Phase-Out With a ±5% PE Stabilizer, G2211 Converts to a 16% Modifier (32% for ACOs) — Comment Deadline September 14 • Prior Auth Enforcement Era: 7-Day / 72-Hour Decision Clocks Live, First Public Payer Denial Scorecards Published March 31, Humana and UHC Gold Card Programs, PA Now 34% of First-Pass Denials • AI Integration Wall: 80% Exploring GenAI, 63% Adopted, 27% at Scale, Only 15% With Realized ROI; Ambient AI Returns 60–90 Minutes/Day and 3.5–6% wRVU Lift • FY 2027 ICD-10-CM: 40-Day Countdown, 190 New Codes Across 33 Clinical Topics, Z86.17, Z68.18/19, E89.830 — Plus the First Maternity CPT Overhaul in 30 Years (59080–59083) • Revenue Velocity: 11.8% Denial Rate, $57 Per Rework, Scrubbing Moves First-Pass Yield 78–82% → 92–95% • KLAS 2026 RCM Suites: Waystar Overall “A”; PitchBook Warns Agentic AI Is Gutting Take Rates After $42.9B in PE Deals • Compliance: Price Transparency Enforcement Live April 1, July 4 FHIR Deadline for CMS Aligned Networks, WISeR Covers 17 Services in 6 States • Independent Practice Watch: 120,900 Independents Left, 82% Employed, MGMA Overhead +29.3% in Five Years • Specialty: Orthopedics −7%, Primary Care G2211 Win, Cardiology ~+1%, Radiology +2–3%, Oncology 340B and Skin Substitutes at $127.28/cm²

FY 2027 IPPS/LTCH Final Rule (CMS-1849-F), Issued August 4: +2.3% Operating Update From a 3.2% Market Basket Less 0.9 Points of Productivity, +$2.1B to Hospitals, +$779M in New Technology Add-On Payments, Three IQR Measures Added and Three Removed, TEAM Expanded to More Spinal Fusion Episodes — Effective October 1 • Two Comment Clocks: OPPS/ASC CMS-1850-P Closes August 31 (340B Moves From ASP+6% to ASP−33.4%, a ~37% Cut; Site-Neutral Extends to Non-Contrast Imaging in Excepted Off-Campus PBDs; IPO List Phase-Out) and CY 2027 PFS Closes September 14 • Prior Auth: 48 Plans and 257 Million Members Under the AHIP Commitments, a 90-Day Continuity-of-Care Window Most Practices Are Not Using, UHC Gold Card Cut PA Volume 30%, and an 80% Real-Time E-PA Mandate Arriving in 2027; WISeR Survived a 46–50 Senate Vote July 16 and Runs to 2031 Across 17 Services, 6 States, 6.4M Beneficiaries • Ambient AI’s Receipts: 15,791 Hours Saved at The Permanente Medical Group, −35% After-Hours Charting and $13,049 Per Clinician at St. Luke’s — Against a 40.4/100 Completeness Score for Ambient-Audio-Only Notes; 63% Adopted, 27% at Scale, 15% With ROI, and IT Infrastructure Is the #1 Barrier at 51% • Coding: 48 Days to FY 2027 ICD-10-CM (238 New, 4 Revised, 21 Deleted; 33 New Codes in O31.4 Alone; D69.1 Splits to D69.11/D69.19; C78./C79. Metastatic Expansion), 58 New Category III CPT Codes, the ABA Rewrite — and G2025 Expires for RHCs and FQHCs in 139 Days • Revenue Velocity: Patient Collections Jump 24% → 31% in One Year as 91.5% Take a Payment Method at the Estimate, While Self-Pay-After-Insurance Falls 5.2% to 29% and POS Sits at 24.4% • Technology: Black Book Rates 420 Vendors Across 49 Categories; XiFin Joins Notable’s Series B August 10; Innovaccer Buys CaduceusHealth (4,000 Practices, $5B in Charges); PitchBook Warns Agentic AI Is Gutting Take Rates • Compliance: Federal IDR Fee Drops $115 → $15 (87%) on 6.34M Disputes, TEFCA Crosses 1 Billion Records, GuardDog Telehealth Permanently Enjoined, Medicaid Work Requirements Start in 140 Days • Independent Practice Watch: 82.0% of Physicians Employed, 253,000 Since 2018, 48,100 in Two Years — but Site-Neutral and 340B Repricing Cut Against the Hospital Arbitrage • Specialty: Orthopedics −7% With Knee and Hip Work RVUs Down 20.8%, Oncology Facing ASP−33.4%, Primary Care Banking APCM at $16.30/$53.50/$116.00 a Month, Behavioral Health Exempt From the 2.5% Efficiency Adjustment

Software as a Medical Service: CMS-1850-P Proposes Status Indicator “O1,” 36 HCPCS Codes Designated SaMS With 21 Moving to New Technology APCs, OPPS/ASC +2.4% — Comment Deadline August 31 • CY 2027 PFS: Conversion Factors $33.1693 / $32.8409, ±5% Practice Expense Stabilizer, Traditional MIPS Sunsets in 2029, New QPP Incentive for Responsible AI Use — Comment Deadline September 14 • Prior Auth on Two Tracks: CMS-0062-P Extends the 7-Day / 72-Hour Clock to Drugs and Proposes FHIR Under HIPAA Administrative Simplification; UHC Gold Card Cut PA Volume 30%, Cigna Has Pulled 1,100+ Codes; MA Denial Rates of 12.8% UHC / 11.9% Aetna / 5.8% Humana • AI in RCM: 63% Adopted, 27% at Scale, 15% With Realized ROI — Only 14% Point AI at Denials Though 69% of Those Who Do See Fewer; CMS Orders Corrective Action on Its Own WISeR AI Contractor • Coding Countdown: 55 Days to FY 2027 ICD-10-CM — 238 New Codes, 4 Revised, 21 Deleted, C78./C79. Expansion, D69.11 and D69.19 — Plus the CPT 2027 Maternity Teardown and 58 New Category III Codes • Revenue Velocity: 11.8% Initial Denial Rate, 15.7% in Medicare Advantage, $57.23 Per Rework; Kodiak Reports $48B Lost Across 2,300 Hospitals; POS Collections Rise to 24.82% While Patient Yield Falls to 30.07% • Technology: Waystar Takes the KLAS 2026 RCM Suites “A,” Ensemble Beats R1 by 42.9 Points, Healthcare RPA Grows to $7.14B by 2033 With a 6–9 Month Payback • Compliance: HIPAA Security Rule Slips to July 2027 With a One-Year BAA Clock, Price Transparency MRF RFI Open to August 31, TEFCA Crosses 500 Million Records • Independent Practice Watch: Only 24% See Their Revenue Leakage, 85,000 Practices Acquired Since 2018, 48,100 Physicians Left Independence Since 2024 — Yet Just 2% Want Out • Specialty: Orthopedics −7%, Cardiology ~+1%, Radiation Oncology Delivery Codes +23%, CTA Chest 71275 +149%, GI Loses 91120 / 91122, Primary Care Gains a 16% G2211 Modifier

CY 2027 OPPS/ASC Proposed Rule: 2.4% Rate Bump, 340B Reimbursement Cut to ASP−33.4%, Imaging Site-Neutral Expansion, Comment Deadline August 31 • MA Prior Auth Denial Surge: 31% YoY Increase, AI Payer Systems Driving Upfront Rejections, 80.7% Overturn Rate When Appealed, Only 11.5% Appealed • Abridge $316M Series E + Availity PA Integration; Microsoft Nuance Tops KLAS CDI; 63% of Providers Have AI But Only 15% Fully Integrated • FY 2027 ICD-10-CM: 62-Day Countdown, 190+ New Codes, O31.4 Vanishing Twin, Z68.18/19 BMI Underweight, J34.83 Odontogenic Sinusitis • WISeR Prepayment Review in 6 States; Automation Boosts Net Collections 15%; KPI Benchmarks for H2 2026 • Ambient AI Duopoly: Abridge vs Nuance; MA Plan Exit Credentialing Crisis in 109+ Counties • Independent Practice Watch: 85,000 Practices Acquired Since 2018, 29,600 MDs to Hospital Employment in 2025, 340B Impact on Consolidation • Specialty: Cardiology 340B/HOPD Imaging, Oncology ASP−33.4% Threat, Ortho CPT Tightening, Mental Health Permanent Telehealth Win

CY 2027 PFS Comment Window Open: ASM Rural Adjustment, Permanent Behavioral Telehealth, MSSP Benchmarking Reform • Payer PA Mid-Year Scorecard: Aetna 88% Standardized, UHC July Policy Drops, 7-Day Decision Clock in Effect • Candid Health $120M Series D (July 22); AI in RCM Market $21.49B Growing 27% CAGR; CodaMetrix 70% Denial Reduction • FY 2027 ICD-10-CM 10 Weeks Out: Oncology Radiation Level 1/2/3 Codes, IMRT Deleted, GI MVP 11 Quality Measures • Revenue Velocity KPIs: 97% Clean Claim Rate Top Target, 3-Gap Automation Audit • KLAS 2026 RCM Suites Report: Waystar ‘A’ Rating, Partnership Quality Predicts ROI • CMS July 2026 Enforcement Dataset Live; MRF Actual Payment Data Required • Independent Practice Watch: $210.4B Market, AI Now Entry Fee Not Differentiator • Specialty: Cardiology ASM Rural Adjustment, Orthopedics 7-Day PA Clock, Mental Health NQTL Enforcement

CY 2027 PFS Proposed Rule: −1.68% Conversion Factor, Same-Day E/M + Global Bundling at 50%, Comment Deadline September 14 • Medicare Advantage Denial Emergency: 17% vs. 8% Traditional Medicare, 2.9M Patients Disenrolled, Authorization-Gap Crisis • Agentic AI Race: $19.71B Market by 2034, What’s Production-Ready Now vs. 2027–2028 • HCPCS Q3 2026 Updates Live, CPT Assistant 2027 L&D Preview, FY 2027 ICD-10 11 Weeks Away • HFMA/Guidehouse: 20% of Practices Exceeding 5% Denial Rate • Price Transparency Phase Two: 500+ Hospital Warning Letters, EDI 835 Required • CMS Drug PA Interoperability Rule: 24-Hour Medicaid Turnarounds • Independent Practice Watch: 18% Physicians Independent, Need 6%+ Growth to Hold Margin • Specialty: APCM G-Codes Live, Oncology 38% Ibrutinib Cut, Radiology MRI Codes 76014–76019

CY 2027 OPPS/ASC Proposed Rule: 340B Restructuring, Site-Neutral Expansion, Botulinum Toxin PA Expansion; Comments Due August 31 • AHIP Pledge Year One: 11% of PA Requirements Eliminated, 6.5M Fewer Requests; Aetna 88% Standardized • The Hybrid Model Wins: AI-Assisted Human Billing, 451% ROI, Clinical Denials Still Need Humans • Mid-Year Coding Audit: Z21 Sequencing, E11.A Remission, BMI-Only Claims Before FY 2027 • Denial Labor Tax: 51–75 Hours/Week, 41% Writing Off $5M+ • RCM M&A Wave: Experity Buys Exdion, Waystar/Iodine $1.25B • HIPAA Security Rule Slips to 2027 but OCR Enforcement Live Now • MGMA 2026 Squeeze: 84% Higher Costs, 47% Higher Revenue • Specialty: ASM Roster Errors, CCM +10%, WISeR States, Oncology 340B

OBBBA Work Requirements Live July 1 in Montana & Arkansas; 6-Month Countdown to Nationwide Rollout • NewYork-Presbyterian Exits UHC MA Network July 1; Continuity-of-Care Window Through September 28 • Task-Level vs. System-Level AI: 63% Adoption, Only 15% Full Integration • NCCI Q3-2026 AOC Edits Live; AX Modifier Eliminated for ESRD TDAPA; HCPCS Quarterly Update July 6 • 2026 RCM Benchmarks: Days in AR Under 30, Clean Claims 98.7%, Denial Rate Below 5% • Black Book AI-RCM Rankings: Waystar, Experian Health, AKASA, R1; $18B Denial Overturning Cost • Q4 2026 Compliance: CMS-0062-P Final Rule Imminent; ICD-10 FY 2027 October 1 • Specialty: RPM Codes 99445/99470, Orthopedics −2.5%, Oncology Navigation Codes, Neurology AI-EEG CPT

OBBBA Coverage Unraveling: 10–17M Medicaid Patients at Risk, $24B Uncompensated Care Projected • Cigna 70% PA Standardization by Year-End; Full Payer PA Scorecard • UiPath BOAT Full-Stack RCM Framework; 86% of Practices Leave Revenue on the Table • EEG Code Family Revisions & 6 New MRI-Safety CPT Codes 76014–76019 • Net Collection Rate Gap: 95%+ Target vs. 83–89% National Median • Fathom in Epic App Orchard; Nym Health Clinical Benchmark; 120+ AI Tools Commoditization Risk • OBBBA Provider Tax Freeze; Audio-Only Telehealth Restrictions; H2 2026 Compliance Calendar • Independent Practice: OBBBA Double Exposure — Medicaid & ACA Marketplace Panels at Risk

MA Network Crisis: 21 Health Systems Exit, 2.9M Enrollees Displaced • UHC 30% PA Reduction Rolling Out: Echocardiograms & Outpatient Surgery PA-Free for 50M Members • Black Book’s 9 Under-the-Radar AI Innovations: Governance Now the Differentiator • FY 2027 ICD-10: 238 New Codes Oct 1; GI Colonoscopy Denial Surge • Smarter Technologies $800M Launch: SmarterDx + Thoughtful.AI + Access Healthcare • Cybersecurity: TriZetto 2.5B-Transaction Breach; TiC Rule Proposed Update • Independent Practice: AI Governance Gap at 77%; M&A Accelerating

URGENT: CMS-0062-P Drug PA Rule Comment Deadline June 15 • Massachusetts Eliminates PA for Primary Care, Cancer Scans & Chronic Disease Meds • HFMA 2026: McKinsey Projects 30–60% Cost-to-Collect Reduction With AI; FinThrive Fusion & UiPath Agentic AI Debuts • Radiation Oncology Overhaul: Level 1/2/3 Replace Simple/Complex; IMRT 77385–77386 Deleted • Cardiology LAA Occlusion wRVU Cut 26.8%; PCI Family Revised • 2026 AR Benchmarks: Days in AR 30–40, Clean Claims ≥95%, AR Aging Ratios • Agentic AI RCM: $1.83B Market Growing to $19.71B by 2034 at 34.61% CAGR • Independent Practice: 30% Revenue Decline; Medicaid Risk Modeling for 2027 • Specialty: Primary Care PIN Codes, Cardiology LAAO Cuts, Oncology Coding Overhaul

CY 2027 MA & Part D Rule Effective June 1: Star Ratings Overhaul, PA Continuity & Part D Redesign • Medicaid Community Engagement IFR: 80 hrs/month Work Requirement, Jan 2027 State Deadline • athenahealth 80+ AI Features: 30% Coding Denial Recovery, 16% Fewer Insurance Denials, PA Voice AI <1hr • CoCM Billing Code Alert: 99492–99494 Retired, G0568–G0570 Required Now • Denial Rates Hit 20%; 60% Never Appealed; Prevention-First KPI Playbook • Black Book Research: 74% Shift to Denial Prevention, Revenue Cycle Now Board-Level Infrastructure • Price Transparency Enforcement Active; Drug PA Comment Deadline ~June 13 • Independent Practice: 15% AI-Integrated; Medicaid Panel Risk Modeling for 2027 • Specialty Spotlight: Cardiology UHC–NYP, Orthopedics −2.5% Cut, Mental Health Telehealth Expansion

CMS-2449-P: $775B Medicaid Supplemental Payment Cap Proposed • UHC Eliminates PA for 30% of Services: 50M Members, Echocardiograms & Outpatient Surgery First • Innovaccer Acquires CaduceusHealth $66M: First Autonomous RCM Platform for 4,000 Providers • CPT 2026 AI-Assisted Diagnostic Codes: Lung Nodule, Stroke AI, Mammogram Comparison Now Billable • 97% Clean Claims Benchmark: 0.3–0.5 AR Days per Point Below • CMS Price Transparency Enforcement Active: Median Allowed Amounts, Type 2 NPI, CEO Attestation Required • Independent Practice: 60% Denied Claims Never Resubmitted — $30K–$80K Recovery per Physician • Specialty Spotlight: Mental Health PA-Exempt, Radiology AI CPT Codes, Cardiology ASM Prep

ASM Mandatory for 8,600 Cardiologists & Back-Pain Specialists Starting Jan 2027 • Aetna 95%+ PAs in 24 hrs; Cigna Migrates to CoverMyMeds • RCM AI Market: $21B → $71B by 2031; Fathom Enters Epic App Orchard • ICD-10-CM FY2026: 487 New Codes — E11.A Diabetes Remission & HIV Z21 Now Audit Risk • Clean Claims Rate: 95% Floor, Zero-Day Denial as Gold Standard • UHC Mandates Full Radiology Interpretation Reports; Waystar IPO • $5.7B Healthcare FCA Recoveries FY2025 — HIPAA Tracking Tech Enforcement • 97% of Practices Outsource RCM; Only 15% AI-Integrated • Specialty Spotlight: Primary Care APM Premium, Cardiology ASM, Oncology CMS-0062-P Deadline

CMS Medicaid Managed Care Final Rule: Network Adequacy & PA Data Reporting Mandated • Gold Carding Expands: Cigna 15K+ Providers, Humana 3-Tier PA Reform • Agentic AI: AKASA 1-Agent = 14 Staff, Thoughtful AI 4.2% Denial Rate • HCC Risk Adjustment Gap: $2.8B Missed by Independent Practices • First-Pass Resolution Rate: The Hidden KPI • Payer AI Denial Engines vs. Counter-AI Platforms • OIG 2026 Work Plan: Telehealth, E/M & Medical Necessity Active Audits • MGMA 2026 Compensation: Independents Earn 12% Less • HPSA Bonus: 10% Medicare Bonus, 2,400 New Designations

CMS-0062-P Drug PA: 24-Hour / 72-Hour Decision Windows, Mandatory ePA by Oct 2027 • UHC Cuts 30% More PAs; Payer Pushback Drives 78% of Payment Delays • Oliver Wyman: 63% of Health Systems Run AI in RCM; Only 8% Expect “Very High” ROI • April 2026 ICD-10-CM Update: Opioid, Autoimmune & Post-COVID Codes • The 25-Day Club: Top Performers Cut Days in A/R Below 25 • CodaMetrix Cuts Coding Denials 59%; 2026 Best in KLAS RCM Winners • Hospital Price Transparency Enforcement Begins April 1 • Only 42.2% of Physicians Still in Private Practice

H.R. 1 Signed: Medicaid Provider Tax Freeze, Payment Caps & One-Year Medicare Lifeline • PA Reform Scoreboard: Aetna 88%, Cigna 70% • Waystar $1.25B Iodine Acquisition • CPT 2026: First AI-Augmented Billing Codes • Top Practices Collecting in Under 24 Days

CMS CY 2027 MA Final Rule Takes Effect; Price Transparency Enforcement Active as of April 1 • AHIP Spring PA Progress Report Due: Reform Pledges Meet the Reality of Still-Rising Denials • Agentic AI Arrives: Waystar Claims $15.5B in Prevented Denials; Only 15% of Providers Fully Integrated • ICD-10-CM Note Changes Now Live in 14 Chapters; Cardiology PCI Overhaul and New AI Diagnostic CT Codes • The 25-Day A/R Target: How Top Performers Are Widening the Gap in 2026

CMS Drops Drug PA Interoperability Rule; H.R. 1 Puts Medicaid Eligibility on a New Clock • The MA Denial Crisis Deepens: 56% Jump in PA Denials, 80.7% Overturned on Appeal • Ambient AI Delivers Measurable Revenue Lift: 11% wRVU Gain, 14% More HCCs Documented • New CPT Codes in Play: AI-Enhanced Cardiac CT Billable, RPM Splits, GI and Neurology Updates • The MA Denial Tax: $47 Per Claim — How Rework Costs Are Eroding Revenue Velocity

Hospital Price Transparency Enforcement Is Live — What Every Practice Must Know Now • PA Reform Wave Continues: UHC, Cigna, Aetna Deliver on January Commitments • Agentic AI Is No Longer a Pilot — Autonomous Revenue Cycle Operations Go Mainstream • April 1 ICD-10-CM Update: Instructional Note Changes That Will Shift Your Coding • Closing the Gap: 2026 RCM Benchmarks and the Revenue Velocity Playbook

CMS Drops CY2027 MA Final Rule and April 1 ICD-10 Notes Reshape Coding — A Week of Back-to-Back Regulatory Moves • PA Transparency Era Begins: March 31 Deadline Forces Payers to Publish Denial Data for the First Time • AI Is Becoming the Revenue Cycle Operating System — Agentic Workflows Now Handle the Full Denial Loop • April 1 ICD-10 Update: No New Codes, But Excludes1-to-Excludes2 Conversions Could Unlock Missed Revenue • Days in A/R, Denial Rates, and Clean Claims: Where the Industry Stands Heading Into Q2

CMS Finalizes Electronic Claims Attachments Rule — $782M in Annual Savings, Fax Machines on Notice • March 31 PA Metrics Deadline Looms as Payers Publicly Report Denial Data for the First Time • HIMSS26 Unleashes Agentic AI Arms Race — Waystar, Epic, and FinThrive Ship Autonomous RCM Agents • 36 New HCPCS Codes Drop April 1 — Plus Critical ICD-10 Excludes 1 Enforcement at UHC • Days in A/R Benchmarks Tighten as Denial Rates Hit 11.8% and $262B in Claims Go Unpaid

Regulatory/Payment Updates — CMS PFS Correction Rule and Part D Out-of-Pocket Cap Take Effect • Prior Authorization / Payer Relations — AHIP Voluntary PA Reforms Now Live; Payers Trim MA Networks • AI & Automation Deep Dive — Agentic AI Crosses Into Autonomous Revenue Cycle Operations • Coding Updates — CPT 2026 Coronary Revascularization Overhaul and Radiation Oncology Code Restructure • Revenue Velocity / KPIs — Zero-Day Denials and the Race to Sub-30 Days in A/R

Medicare Advantage Plans Cut Benefits and Geographic Coverage for 2026 • Prior Authorization Real-Time Decision Mandate: 80% by 2027 • Healthcare Eligibility Verification Automation: 60-90% of Verifications Now Autonomous • FY 2026 ICD-10-CM Guidelines: Major HIV Coding Revisions Take Effect • RPA Adoption in Revenue Cycle Management Reaches 50-75% of U.S. Hospitals

CMS Physician Fee Schedule 2026: 3.26% Rate Increase and Key Payment Updates • Prior Authorization Reform Takes Effect: Industry-Led 72-Hour Response Commitment • AI-Powered RCM Reaches Critical Mass: 63% of Providers Already Using AI • CPT 2026 Recognizes AI-Augmented Services for the First Time • Denial Rates Surge to 15%: AI Denial Prevention Becomes Standard Practice

Medicare Advantage Market Disruption: 10% of Enrollees Forced to Switch Plans • RADV Audits Accelerate: Payment Year 2020 Reviews Now Underway • The Autonomous Coding Revolution: AI Medical Coding Market Update • ICD-10 and CPT 2026: Critical Guideline Changes You May Have Missed • Denial Management in 2026: Upstream Prevention Replaces Downstream Recovery

CMS 2026 Payment Updates: What Your Practice Needs to Know • Prior Authorization Reform: 50+ Payers Commit to Major Changes • AI and Automation: The Agentic Revolution in RCM • CPT and ICD-10 Code Updates for 2026 • Revenue Velocity: 7 KPIs Every Practice Should Track